In the Proposed Rule, FinCEN proposes to require financial institutions to impose “special measures” against Liberty Reserve, S.A. (“Liberty Re serve”) under Section 311 of the Bank Secrecy Act. As discussed below, the Bitcoin Foundation does not take issue with the imposition of special measures against Liberty Reserve. Rather, the Bitcoin Foundation is filing these comments to urge FinCEN to c larify statements made in the Proposed Rule and the underlying Notice of Findings that could be misinterpreted to suggest that virtual currency transactions in general are inherently suspect.